The Oyez Project: Criminal Procedure Issues - Plea Bargaining Decisions

Blackledge v. Allison

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Blackledge v. Perry

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Bordenkircher v. Hayes

Does the Fourteenth Amendment's Due Process Clause prohibit state prosecutors from carrying out a threat made during plea negotiations to re-indict the accused on more serious charges if he does not plead guilty to the offense with which he was originally charged?

No. The Court held that the defendant's due process rights were not violated in this case. Justice Stewart spent some time describing the important role that plea bargaining plays in the nation's legal system, a role that has been accepted by the Supreme Court in cases such as Blackledge v. Allison (1977) and Brady v. United States (1970). This acceptance, in turn, implies that the prosecutor has a legitimate interest in persuading a defendant to relinquish his or her right to plead not guilty. Threatening a stiffer sentence is permissible and part of "any legitimate system which tolerates and encourages the negotiation of pleas," Stewart declared.

Bousley v. United States

May defendants who pleaded guilty to "using" a firearm in violation of 18 USC section 924(c)(1) contest the validity of their convictions by claiming that their guilty pleas were not knowing and intelligent because they were misinformed by the District Court as to the nature of the charged crime?

Yes. In a 7-2 opinion delivered by Chief Justice William H. Rehnquist, the Court held that, although Bousley's claim was procedurally defaulted, Bousley may be entitled to a hearing on the merits of it if he makes the necessary showing to relieve the default. The Court's opinion made Bailey v. United States, 516 U.S. 137 (1995), which held that section 924(c)(1)'s "use" element requires the Government to show "active employment of the firearm," retroactive. Accordingly, the Court ruled that Bousley need demonstrate no more than that he did not "use" a firearm as defined in Bailey to be entitled to have his defaulted claim of an unintelligent plea considered on its merits.

Boykin v. Alabama

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Bradshaw v. Stumpf

(1) Was Stumpf's guilty plea to aggravated murder knowing, voluntary and intelligent? (2) Was his conviction valid, despite the state's use of a theory in the trial of Stumpf's accomplice that was inconsistent with its argument in Stumpf's trial?

Yes and possibly not. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that Stumpf's plea was knowing and therefore valid, because his attorneys at the plea hearing had represented that they had explained the elements to Stumpf, who then confirmed this. The Court articulated the broad rule that constitutional requirements were satisfied when a defendant's competent counsel explained to him the charge's nature and the crime's elements. As for the prosecution's use of inconsistent theories in Stumpf's and Wesley's trials, the Court held that Stumpf's sentence may have been invalid, depending on the relationship between the prosecutor's conduct and Stumpf's death sentence.. The Court sent the question of that relationship back to the Sixth Circuit.

Brady v. U. S.

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Corbitt v. New Jersey

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Dukes v. Warden

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Godinez, Warden v. Moran

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Henderson v. Morgan

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Hill v. Lockhart

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Mabry v. Johnson

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Machibroda v. United States

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Marshall v. Lonberger

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Mccarthy v. United States

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Mcmann v. Richardson

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North Carolina v. Alford

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Parke, Warden v. Raley

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Parker v. North Carolina

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Santobello v. New York

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Tollett v. Henderson

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United States v. Dominguez Benitez

In order to show that a judge's mistake is a reversible "plain error" under Federal Rule of Criminal Procedure 52, must a defendant show that it is reasonably likely he would not have pled guilty without the mistake?

Yes. In a unanimous decision, the Court ruled that the judge's error most likely had no effect on Dominguez's decision to plead guilty, because he had already confessed to the crime and had little chance of winning at trial. Under Rule 52, a plain error is an "error that affects substantial rights." Because the error did not harm Dominguez - he would likely have pled guilty anyway - it was not a reversible plain error. Justice David H. Souter, writing for 8 members of the Court (Justice Antonin Scalia wrote a separate opinion concurring in judgment), wrote, "The point of the question is not to second-guess a defendant's actual decision... The point, rather, is to enquire whether the omitted warning would have made the difference required by the standard of reasonable probability; it is hard to see here how the warning could have had an effect on Dominguez's assessment of his strategic position."

United States v. Goodwin

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United States v. Ruiz

Do the Fifth and Sixth Amendments require federal prosecutors, before entering into a binding plea agreement with a criminal defendant, to disclose impeachment information relating to any informants or other witnesses?

No. In a 9-0 opinion delivered by Stephen G. Breyer, the Court held that the Constitution does not require the Government to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant. Although the Fifth and Sixth Amendments provide that defendants have the right to receive exculpatory impeachment material from prosecutors, the Court reasoned that a criminal defendant's guilty plea under the plea agreement, with its accompanying waiver of constitutional rights, could have been accepted as knowing and voluntary despite any misapprehension by Ruiz concerning the specific extent or nature of the impeachment evidence. Furthermore, Justice Breyer noted that requiring disclosure of the evidence would improperly force the Government to engage in substantial trial preparation prior to plea bargaining.